Firm Description Founded in 1972, Wilshire Advisors LLC (“Wilshire” or the “Firm”) is a diversified financial services company registered as an investment adviser in the United States with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), providing leading global investment technology, investment consulting and investment management services in conjunction with and through global operating affiliates. Wilshire is headquartered in Santa Monica, California with over 290 employees in 9 offices. Biographical information on certain key personnel is contained in the supplement to this Brochure. Principal Owners Wilshire is controlled by Monica Holdco (US), Inc. Monica Holdco (US), Inc. is in turn indirectly controlled by CC Monica Holdings, LLC, and Motive Monica LP (together with their respective affiliates, the “Owners”). CC Monica Holdings, LLC is advised by CC Capital, a private investment firm based in New York City. Motive Monica LP is advised by Motive Partners, a specialist private equity firm with offices in New York City and London. Types of Advisory Services Wilshire provides diverse discretionary and non-discretionary investment advisory and management services and products to funds, accounts, investors, and intermediaries. Wilshire has assets under advisement1 of approximately $1,431,573,429,875 as of December 31, 2023, including approximately $121,621,056,705 in assets under management. The amounts disclosed for, and the methodology used to calculate, assets under advisement and assets under management differs from that of our regulatory assets under management disclosed in Part 1A of our Form ADV. Wilshire assists clients (as described below) in developing and implementing an investment plan, primarily through the provision of three distinct, yet interrelated, services: (i) asset allocation, (ii) manager research, and (iii) portfolio construction. Each of the foregoing services may be provided separately or combined into a comprehensive service. In general, Wilshire does not provide investment management services in the context of managing a portfolio of individual securities or instruments, but instead provides customized allocations and portfolios focused on recommending specific third-party investment managers or investments in pooled investment vehicles advised by such third-party managers. Wilshire provides discretionary or non-discretionary investment management services to funds, accounts, investors, institutions, and financial intermediaries as follows:
• Wilshire-sponsored funds for which either (i) Wilshire engages third-party investment managers (any third-party investment manager, an “External Manager”) to serve as sub-adviser to manage the investment portfolios, (ii) Wilshire directs fund investments into funds sponsored by third parties (“External Funds”), or (iii) Wilshire offers investors an opportunity to invest in or opt-in/out of specific investment opportunities in External Funds. Such sponsored funds include Wilshire’s private funds, the Wilshire Mutual Funds and Variable Insurance Trusts (VITs), the Wilshire Solutions Funds Trust, the Wilshire Institutional Master Funds, and Wilshire’s Collective Investment Trusts (“CITs”)
• Separately managed accounts comprising direct fund investments into External Funds, allocation to External Managers, or other investment advice with respect to a client’s portfolio of External Funds
• Registered investment companies and External Funds for which Wilshire serves as sub-adviser with discretion over security selection, asset allocation and/or manager selection 1 Assets under advisement” refer to various consulting and advisory relationships for which Wilshire provides investment advisory services without engaging, on either a discretionary or non-discretionary basis, in the direct management of a client’s portfolio. wilshire.com | T +1 310 451 3051 | ©2024 Wilshire Advisors LLC. All Rights Reserved. 5
• Outsourced Chief Investment Officer (“OCIO”) services where Wilshire has the discretion to hire and terminate investment managers and rebalance portfolio assets
• Model portfolios where Wilshire has discretion over the model
• Wrap programs sponsored by third parties where Wilshire has discretion over security selection, asset allocation and/or manager selection (“Wrap Accounts”)
• Retirement and pension plans where Wilshire has discretion over security selection, asset allocation and/or manager selection
• Delegated consulting where Wilshire has the discretion to adjust the asset allocation of a portfolio

to maintain a prescribed risk profile Wilshire-sponsored funds may also be sub-advised by one or more unaffiliated third-party investment managers to whom Wilshire delegates discretionary trading authority and who sub-advises the fund subject to a trading advisory agreement (“Trading Advisor”). The Trading Advisor will often have broad investment authority over the fund, subject to overall oversight and setting of the investment strategy and guidelines by, and certain rights of, Wilshire. References to “clients” throughout this Brochure refer to the above-mentioned funds, accounts, investors, institutions and financial intermediaries. Absent a separate advisory relationship with Wilshire, investors in funds, External Funds, and third- party feeder vehicles are not deemed to be Wilshire “clients” under the Advisers Act but are entitled to the rights and benefits described in the applicable disclosure documents, management agreements, limited liability company agreements and other applicable constituent documents. In providing each of its services, Wilshire takes into account each client’s risk tolerances, return goals, and any legal or regulatory restrictions. Clients are provided with regular reports detailing Wilshire’s assessment. Clients may be given access to Wilshire’s qualitative and quantitative software tools to assist in developing and implementing investment objectives. Services may cover public and/or private markets, depending on client needs. Wilshire is a diversified financial services firm and therefore Wilshire’s products, services, investment approach and advice differ between clients (including discretionary accounts and even where similarly situated) and not all of Wilshire’s products and services are available to all clients. Clients may utilize different classes of the same issuer that have different rights, including, without limitation, with respect to liquidity and fees. Wilshire receives a share of the fees charged to clients of Wrap Accounts, and may benefit from the marketing, computer reporting and client screening services of the Wrap Account sponsors. Client Agreements Prior to the start of any client relationship, Wilshire enters into an agreement with the client. The agreement outlines the terms and conditions of the relationship including a description of the services to be provided by Wilshire, responsibilities of the client, fees and other standard contractual terms. Investment goals, objectives and/or guidelines for each advisory client are documented in each client agreement. Clients may impose restrictions on investing in certain securities or types of securities, or whether Wilshire’s services are provided on an open architecture model (in which Wilshire uses exclusively third-party products to implement the client’s investment plan) or a proprietary products service model (in which, for the strategies and asset classes covered by Wilshire products, Wilshire products will be the only available options). Advisory agreements may not be amended or assigned without client consent, which consent may be provided through negative consent in certain circumstances. Non-Investment Advisory Services Types of Services Wilshire has over fifty years of expertise providing investment firms worldwide with multi-asset class solutions for global risk and performance attribution analytics, asset allocation modeling, manager evaluations and peer analysis, and GIPS reporting. Institutions served include central and custodial banks, asset management firms, insurance companies, plan sponsors, mutual fund companies and hedge funds. Our customers benefit from access to comprehensive security data, time-tested models, and flexible reporting capabilities, including data visualization dashboards powered by business intelligence tools such as Microsoft Power BI or Tableau. Robust capability sets such as scenario analysis and portfolio wilshire.com | T +1 310 451 3051 | ©2024 Wilshire Advisors LLC. All Rights Reserved. 6 optimization help clients make better investment decisions and evaluate their impact. Services include Wilshire Compass, Wilshire Trust Universe Comparison Services, Wilshire Axiom, Wilshire Atlas, Wilshire Abacus, and Wilshire iQComposite. Customer Agreements Prior to the start of any customer relationship for non-investment advisory services, Wilshire enters into an agreement with the customer. The agreement outlines the terms and conditions of the relationship including a description of the services to be provided by Wilshire, including licenses to utilize Wilshire’s analytical tools, responsibilities of the customer, fees and other standard contractual terms. wilshire.com | T +1 310 451 3051 | ©2024 Wilshire Advisors LLC. All Rights Reserved. 7